Level I inspections occur through out the country on a regular basis. We as carriers, are subject to these roadside safety compliance checks in single or multiple jurisdictions during each day's travel. The Commercial Vehicle Safety Alliance, along with its enforcement partners developed a method to identify vehicles that have been inspected and were deemed to be free of critical item defects. My understanding was that the goal in the CVSA decal issuance was multifaceted. One goal was to let other inspectors know that a vehicle had been inspected and found free of critical item defects, thus allowing them to focus on other vehicles. It was also our understanding, a way to clear a vehicle from being inspected constantly as it passed through multiple jurisdictions or even within the same. Over time the issuance of CVSA decals after the competition of a Level I inspection has declined. This is not an isolated issue. It occurs in numerous jurisdictions across the country. There are multiple reasons given as to why a decal was not issued. Some are simply "I am out of decals". If the inspection is performed by an agency that is a CVSA member, the Memorandum of Understanding (MOU) signed by each agency requires adherence to all CVSA policies, inspection guidance and procedures. The decal issuance from my understanding is a CVSA policy requirement. It is imperative when policies are created that they are also followed. When they are not, it fosters the feeling of the rules apply to carriers but not enforcement. When the roadside inspection is performed on the commercial vehicle, it is a necessary task to ensure highway safety. Multiple inspections on the same vehicles that were required to be issued a CVSA decal and were not, are a quantifiable expense to the carrier that does not increase highway safety.

Failing to issue a CVSA decal after a Level I inspection with no critical item defects is creating a negative effect on CMV safety. It is a direct expense to carriers in time and equipment utilization. It also diverts enforcement resources from other vehicles not previously examined. CVSA Operational Policy 5 and the Policy Statement in Section II of the North American Standard Out of Service Criteria require that a CVSA decal SHALL be applied to the vehicle if it has no critical item defects found in a Level I or V inspection.

I request that language be placed in Operational Policy 5 and the Policy Statement in Section II of the OOSC that prohibits an inspector from initiating a Level I or V inspection unless the inspector possess CVSA decals sufficient to complete the inspection if no critical item defects are discovered. Other levels of inspection not requiring a decal to be issued may be completed if CVSA decals are not available.

The language placed in each part could simply state the following,
"A Level I or V inspection cannot be initiated unless CVSA decals are available for each vehicle inspected. The decal SHALL be issued if no critical item defect is discovered on a vehicle. It SHALL be placed on each vehicle inspected in the location designated in the OOSC."